# PLACER COUNTY AIR POLLUTION CONTROL DISTRICT

STAFF REPORT

201 4 Reasonably Avail able Control Technology State Implementation Plan Analysis

February 201 423 BACKGROUND

Purpose

The Placer County Air Pollution Control District ( District ) is required to update the Reasonably Avai lable Control Technology State Implementation Plan ( “RACT SIP ” ) analysis

. This requirement results from the District’s classification as “ s evere ” non

- attainment with the national eight

- hour ozone ambient air quality standard, and als o non

- attainment with the State of California ozone standard

.
District Air Quality Attainment Status

The District ’s jurisdiction is all of Placer County . Placer County is located in northern California

, border ing Sacramento County to the west a nd the State of N evada on the east. Elevations range from near sea level in the western portion of the County to 9,000 feet in the mountains of the Sierras. Placer County is the only county in the s tate that is divided into three different air basins: the Sacramento Valley Air Basin (SVAB); the Mountain Counties Air Basin (MCAB); and the Lake Tahoe Air Basin (LTAB). Each air basin has its own meteorological and geograph ic conditions. Generally, the m editerranean climate in SVAB has summers that are hot and dry

, with temperature s regularly above 90  ̊ F

. These hot and dry summers are conduc ive to ozone formation. P revailing winds from the w est transport ozone from the San Francisco Bay Area and the Sacramento Valley into the foothill and mountain area s

.
The portions of Placer County in the SVAB and MCAB are included in the Sacramento Federal Ozone Non

- Attainment Area (SFONA ). The SFONA has been classified as “ severe ” non

attainment for the National Ambient Air Quality S tandard (NAAQS) for eight

- hour ozone, as well

as non

- attainment with the State of California Ambient Air Quality Standard for ozone

.
Federal RACT SIP Requirement

The U.S. Environmental Protection Agency’s ( U.S EPA) Phase 2 Ozone Rule (40 CFR 51.912 and 70 FR 71612) requires that areas that are classified as moderate non

- attainment or h igher
must demonstrate in a State Implementation Plan ( SIP ) that their rules fulfill R easonably Available Control Technology (RACT) requirements for volatile organic c ompounds ( VOC ) and nitrogen oxides (NOx) which are ozone precursors , in accordance with Federal Clean Air Act Amendment s of 1990 (CAAA)

, Sections 182(b)(2) and 182 (f)

.

RACT is defined as “the lowest emission s limitation that a particular source is capable of meeting by th e application of control technology that is reasonably available considering technological and economic feasibility ” ( 44 FR 53762 ). The implementation of RACT requires :

**•** Rules covering source categories with RACT guidance documents

-- including Control Techniques Guideline (CTG)

-- issued by U.S. EPA

, for which there are sources in the District that have emission levels that trigger the RACT guidance document threshold

.

**•** Rules covering all major s ources of NOx or VOC that are in the District

.

CTG guidance must be adopted in District rules, and RACT SIP revisions

, generally within one year of the CTG issuance date.

State of California Ozone Reduction Requirements

In addition to federal SIP requirements, the District has chosen to implement “every feasible measure” (EFM) to meet the ozone reduction requirements under State of California Health and Safety Code Section 40914 (a)(2)

. The State of California suggests that EFMs consider regulations that have been successfully implemented elsewhere ; consi der new technologies and innovativ e approaches; and social, environmental, energy, and economic (cost effectiveness) factors.4 Additionally, the District requires the use of Best Availab le Retrofit Control Technology (BARCT) for VOC and NOx as required under State of California Health and Safety Code Section 40919

.
District Planning History

T he District has adopted numerous air qu ality attainment plans since 1991 to move toward attainment of the NAAQS for ozone. O ver 100 new rules and amendments have been adopted to meet the commitments in these attainment plans. The District is going to work with other air districts in the SFONA to prepare an “Eight

- Hour Ozone A ttainment Plan” for achieving the federal 2008 8

- hou r ozone standard (0.075 ppm)

.

Title Board Adoption 1991 Placer County Air Quality Attainment Plan March 1992
1994 Ozone Attainment Demonstration Plan December 1994 1997 Triennial Progress Report July 1998 1999 Sacramento Area Regional Milestone Report April 2000 2000 Triennial Progress Report April 2001 2002 Sacramento Area Regional Milestone Report May 2003 2003 Triennial Progress Report October 2005 Sacramento Regional Non

- A ttainment Area E ight

- Hour Ozone Rate

- of

- Progress Plan February 2006

Sacramento Regional Non

- Attainment Area E ight

- Hour Ozone and Reasonable Further Progress Plan February 2009

2009 Triennial Progress Report August 2010

2012 Triennial Progress Report October 2013
Sacramento Regional PM2.5 Implementation/Maintenance Plan and Re

- Designation Request February 2014

District RACT SIP History

The District last conduc ted a RACT SIP analysis in 2006. This analysis required a new rulemaking for the Metal Parts and Products source category , which was accomplished by the District through new District Rule 245, SURFACE COATING OF METAL PARTS AND PRODUCTS, adopted on 12/11/08

, amended on 08/20/09, and recently SIP approved by U.S. EPA. The analysis also found th at nine (9) District rules required re

- submittal for SIP approval due to amendments that predated the last SIP approval, and nine (9) District rules that needed first

- time SIP approval. The District is in the process of getting the rules into the approved SIP

, and is under on going s tate and U.S. EPA review

.
The 2006 RACT SIP analysis was followed by a subsequent partial update in 2008 , in response to seven (7) new CTGs

.

In 2011

, a comprehensive analysis of RACT and Every Feasible Measure was conducted as well

as an assessment of existing District rules requiring administrative amendment. The 2011 RACT SIP Analysis identified seven ( 7 ) District rules that required amendment to meet RACT and that one new RACT rule was required.5 ANALYSIS METHODOLOGY

RACT SIP

The RACT SIP analysis involves the following procedures, consistent with U.S. EPA Region IX
g uidance (as contained in a letter from Andrew Steckel dated March 9, 2006 ):

**•** Source Category Identification : I dentify all source categories in the Di strict that require RACT . This must include:

- Source c ategories which have RACT guidance , and for which any sources (either minor or major) operate in the District.

- Source c ategories for which major sources of NOx or VOC operate in the District

.

**•** RACT Determination : For each source categor y that requires RACT, identify if there is a District Rule. If there is no rule, then a new District rule that meets RACT must be developed and promulgated. If there is an existing Di strict rule, then a determination must be made if the existing District rule reflect s RACT. This is based on an analysis of the applicable District rule with guidance and regulations used to establish RACT :

- Federal U.S. EPA : C ontrol T echnique G uidelines (CTG) , A lternative C ontrol T echniques (ACT) , M aximum Achievable Control Technology (MACT) and National Emissions Standards Hazardous Air Pollutant (NESHAP) S tandards, and New Source Performance Standards (NSPS)

.

- State: State of Califo rnia Suggested Control Measures , and S tate RACT guidance

.

- Local: Air Districts in our region.

The RACT determination will identify for each source category :

- E xisting District rule s that meet RACT.

- Existing District rule s that require amendment s to meet RACT.

- N ew rule s required to meet RACT.

**•** Negative Declaration : N egative declarations are required for all source categories for which there is federal RACT guidance

, but for which there are no operating facilities (major or minor) within the District, or for which there are facilities that hav e emissions below the RACT guidance threshold

.
To determine that there are no operating facilities in the District that fall under a source category with RACT guidance

, the following checks were conducted :

- District internal database of permitted sources.

- Internet website searches for key words.

- Business listings through city and county databases.

- Industrial trade groups.

- Yellow pages.

E very F easible M easure

The EFM determination is based on a compar ison of existing District rules with those in other d istricts in the Sacramento region.6 RACT ANALYSIS

Identification of Source Categories

S ource categories considered for the RACT SIP analysis include:

**•** All source categories that are affected by RACT guidance documents that have been published by the U.S. EPA. There are a total of fifty

- one ( 51 ) source categories with RACT guidance documents

-- including 31 CTGs, 1 8 ACTs, and 2 others (NSPS, MACT , and CA RB Suggested Control Measures ).

**•** All source categories that are affected by existing District rules that limit NOx or VOC. There are a total of twenty

- four (2 4 ) District rules that limit NOx or VOC.

**•** All m ajor sources of VOC or NOx that operate in the District. District Rule 502

, NEW SOURCE REVIEW

, defines major sources as those with permitted potential to emit greater than 25 tons per year of NOx or VOC

. There are four major sources in the District

– Rio Bravo Rocklin, Sierra Pacif ic Industries, PABCO/Gladding McBean, and R oseville Electric Energy Park. PABCO/Gladding McBean is major for carbon monoxide, and the remaing three major sources are major for NOx. These three sources represent t wo categories with existing District rules that control NOx: Rule 23 3

, BIOMASS BOILERS , and Rule 2 50

, STATIONARY GAS TURBINES

.

RACT Determination

Existing D istrict R ules Determined to Meet RACT

Table 1 lists the nineteen (19 ) source categories for which there is a n existing District rule that has been determined to satisf y RACT requirements . The table contains the following information: source category title; applicable federal guidance title, report number, and date ; existing District rule number, title, and date of last rule amendment, if any; status and size of operating sources in the District; SIP approval status of the most recent District rule amendment , including Federal Register citation and publication date ; and narrative discussion forming the basis for the determination that the rule meets RACT

.

The table is divided into two sections:

**•** District rules for which the latest rule amendment has been SIP approved by U.S. EPA

. These rules have been determined to meet RACT requirements because they have been reviewed and approved by the State of California Air Resources Board and U.S. EPA, and there has been no more

- recent RACT guidance issued for the source category since the rule was SIP approved by U.S. EPA. Also, the rules have been determined to be consistent with state and regional District rules. There are six teen (1 6 ) rules in this category.

**•** District rules for which the last amendment has not been SIP approved by U.S. EPA. These rules have been determined to meet RACT because they meet the most recent RACT guidance , and have been determined to be consistent with state and regional d istrict rules. These rules have been either adopted by the District and submitted to the State of California Air Resources Board for adoption and forwarding to U.S. EPA, or they have been submitted to U.S. EPA and are awaiting approval. There are t hree ( 3 ) rules in this category.

Determination that the existing District rule s meet the applic able RACT guidance document s is made through a detailed comparison of the District rule with the RACT guidance doc ument compliance requirements

, including control measures through recommended limits on the volatile organic content of coatings and othe r VOC containing products; contro l device efficiency limitations; NOx limi ts from fuel combustion sources; recordkeeping and reporting; and test methods.7 Determination that existing District rules are consistent with r egional d istrict rules is made through

a s urvey and contact with Districts in our region, including Sacramento, El Dorado, and Yolo

Solano.

Existing District Rules to be Amended

Although at the time of 2011 RACT SIP Analysis

, th e re were seven ( 7 ) existing District rules that have been determined to need amendment to meet RACT , there are currently no existing rules that must be amended to meet RACT. The seven (7) previously identified rules were either amended or were determined to meet RACT upon the more detailed review involved as a part of the rule amendment process. Furthermore, there were no other District existing rules that have been found to need amendment to meet RACT.

New District Rules

There are no new rules that are required to be adopted to meet RACT. The District has adopted rules that meet RACT for each source category for which a Control Technique Guideline (CTG) document has been developed by U.S. EPA where there is source in that category in the District that exceeds the RACT guidance threshold. The rule identified as requiring adoption in the 2011 RACT SIP Analysis, for plastic parts coating, was adopted on August 8, 2013 as Rule 249, SURFACE COATING OF PLASTIC PARTS AND PRODUCTS.

N egative D eclarations

Table 2 list s the sixteen ( 1 6 ) source categories for which there is RACT guidance ( CTG ) , but for which the District has determined there are no sources in the category, or if any sources were found

, the s ource ’ s potential VOC and NOx emissions are less than the RACT guidance threshold. A negative declaration will be adopted for these sixteen (16) source categories, asserting that there are no sources exceeding RACT guidance thresholds located in the District. The 2011 RACT SIP Analysis identified fifteen RACT categories. The category of “Dry Cleaning (Petroleum)” which had an adopted control measure Rule 227 that was rescinded on April 12, 2012, is the sixteenth category. Rule 227 was not a SIP commitment and it was re s cinded in favor of regulating this category through 40 CFR 60 Subp art JJJ

.

I f new sources locate in the District in the future

, they will be subject to N ew Source Review requirements under District Rule 502, NEW SOURCE REVIEW. These requirements would be significantly more stringent than RACT

.

Table 2 also lists fourteen ( 14 ) source categories for which there is ACT guidance, but for which the District does not have any such sources.

Every Feasible Measure

Table 3 lists all source categories for which the state has identified the requir e ment of an evaluation for the need of Every Feasible Measure. It has been determined that existing District rules, and new District rules or amendments that will be the outcome of the above analysis of this report, satisfy EFM requirements, as docu mented in Table 3

.

New Rules to be Adopted to Meet “ Sacramento Re giona l 8

- Hour Ozone Attainment and Re a sonable Further Progress Plan ”

The District has no outstanding and unfulfilled commitments for new rules as part of our “Sacramento Regional 8

- Hour Ozone Attainment and Reasonable Further Progress Plan” ( Regional Attainment Plan )

.
The Regional Attainment Plan will undergo revisions in 2015/2016 , which may result in selection of new rulemakings for additional source categories

.8 ANALYSIS

The following analysis and the subsequent f indings are intended to address the requirements set forth in the California Health and Safety Code relating to adoption of RACT SIP Analysis (and new or amended District r ule s) , as well as other s t ate statutes referenced herein.

1. Cost

- Effectiveness of a Control Measure

California Health & Safety Cod e (H&S) Section 40703 requires the Distri ct to consider and make public the “ cost

- effectiveness ” of District control measures

. The cost effectiveness of the RACT SIP Analysis findings and recommendation

— the new rules and rule amendments needed to meet RACT

— will be assessed in detail when each of the separate rules are developed and adopted by the Board in the future to ensure that they are acceptable

. There is no immediate cost impact of these RACT SIP Analysis recommendations.

2. Socioeconomic Impact

H&S Section 40728, in relevant part, requires the Board to consider the socioeconomic impact of any new or amended rule if air quality or emission limits are significantly affected. The expected socioeconomic impact of the RACT SIP Analysis (and new rules and rule amendments to meet RACT ) will be assessed when the rules are adopted to ensure that they are acceptable

.

3. E nvironmental R eview and C ompliance

California Public Resources Code Section 21159 requires that an environmental analysis of the reasonably foreseeable methods of compl iance should be conducted. The RACT SIP analysis (and new rules and rule amendment s required to meet RACT ) will reduce emissions from sources and will not cause any significant adverse effects on the environment. There are no adverse environmental impacts that will be caused by compliance with the new rules and rule amendments

. Nonetheless, an environmental review will be conducted at the time each rule or rule amendment is proposed for adoption.

T he RACT SIP analysis is exempt from the California Environmental Quality Act (CEQA) because : ( 1) it can be seen with certainty that there is no possibility that the activity in question may have a significant adverse effect on the environment (CEQA Guidelines §15061(b)(3)) ; and ( 2) it is an action by a regulatory agency for protection of the environment (Class 8 Categorical Exemption, CEQA Guidelines §15308).

FINDINGS

A. Necessity : The adoption of RACT SIP analysis satisfies the District ’ s objective to reduce VOCs to achieve attainment with ambient air standards for ozone, and meets the District’s requirements to implement “every feasible measure” as required under California Health and Safety Code Sections 40919

.

B. Authority : California He alth and Safety Code, Sections 40000, 40001, 40701, 40702, 40716

, 41010, and 41013, are provisions of law that provide the District with the authority to adopt this RACT SIP analysis

.

C. Clarity : There is no indication at this time that the RACT SIP analysis is written in such a manner that persons affected by the analysis cannot easily understand them.

D. Consistency : The RACT SIP analysis is in harmony with, and not in conflict with or contradictory to, existing statutes, court decisions, or state or federal regulations.

E. Non

- D uplication : The RACT SIP analysis does not impose the same requirements as an existing state or federal regulation.9 F. Reference : All statutes, court decisions, and other provisions of law used by the District in interpreting this RACT SIP analysis are incorporated into this analysis and this finding by reference.

SUMMARY

The RAC T SIP analysis has determined the need for the following District action :

**•** Negative declaration

. A n egative declaration asserting that there are no existing sources in the District or sources that emit above the RACT guidance (CTG) threshold limit for the six teen ( 1 6 ) source categories, listed in Table 2

.10

### Table 1 Existing District Rules Determined to Meet RACTTable 1. Existing District Rules That Have Been Determined to Meet RACT

Table 1 - Page 1 of 7 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT),
and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Analysis Used to Determine that the Rule Meets RACT

Adhesives Control Technique Guidelines for Miscellaneous Industrial Adhesives (EPA 453/R-08-005, 09/08); NESHAP Subpart FFFF, Misc. Organic Chemical Production and Processes (MON) (11/10/03) Rule 235, Adhesives (10/11/12) Minor 78 FR 53711 8/30/13, effective 10/29/13 (10/11/12) Rule 235 meets RACT.

Architectural Coatings National VOC Emission Standards for Architectural Coatings (40 CFR 59 Subpart D, 63 FR 176: 48848, 09/98) Rule 218, Architectural Coatings (10/14/10) Minor 76 FR 75795 12/5/11 , effective 2/3/12 (10/14/10) Rule 218 (10/14/10) meets RACT. It meets Federal VOCs requirements. It was updated to meet California's Suggested Control Measure (2007).

Automotive Refinishing Reduction of Volatile Organic Compound Emissions from Automobile Refinishing (EPA-450/3-88-009, 10/88); National VOC Emission Standards for Automobile Refinish Coatings (40 CFR 59 Subpart B, 09/98) Rule 234, Automotive Refinishing (10/14/10) Minor 76 FR 75795 12/5/11, effective 2/3/12 (10/14/10) Rule 234 (10/14/10) meets RACT. It meets Federal requirements for VOCs. It was updated to meet California's Suggested Control Measure (2005).

Boilers, Biomass New Source Performance Standards for Industrial-Commercial-Institutional Steam Generating Units (40 CFR 60 Subpart Db, 06/03) Rule 233, Biomass Boilers (06/14/12) Major 78 FR53249 8/29/13 (06/14/12) Rule 233 meets RACT.

Boilers, Water Heaters ≥ 5 million Btu/hr NOx Emissions from Process Heaters (EPA-453/R-93-034, 09/93); NOxEmissions from Utility Boilers (EPA-453/R94-023, 03/94); NOx Emissions from Industrial / Commercial / Institutional Boilers (EPA-453/R-94-022, 03/94) Rule 231, Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters (10/09/97) Minor 76 FR 67366 11/1/11, effective 1/3/12 (10/09/97) Rule 231 (10/09/97) meets RACT. It meets the ACT. District Rules that are Approved in the California SIPTable 1. Existing District Rules That Have Been Determined to Meet RACT

Table 1 - Page 2 of 7 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT),
and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Analysis Used to Determine that the Rule Meets RACT

Cutback Asphalt Control of VOC from Use of Cutback Asphalt (EPA-450/2-77-037, 12/77) Rule 217, Cutback and Emulsified Asphalt Paving Materials (10/19/93) Minor 62 FR 23365 04/30/97 (10/19/93) Rule 217 meets RACT.

Flat Wood Paneling Coatings Control of Volatile Organic Emissions from Existing Stationary Sources for Factory Surface Coating of Flat Wood Paneling (EPA-450/2-78-032, 06/78); Control of Volatile Organic Emissions from Existing Stationary Sources Control Technique Guidelines for Flat Wood Paneling Coatings (EPA-453/R-06-004, 09/06) Rule 238, Factory Coating of Flat Wood Paneling (10/14/10) Minor 76 FR 71886 11/21/11, effective 1/20/12 (10/14/10) Rule 238 (10/14/10) meets RACT. It was amended to meet the CTG.

Gas Turbines NOx Emissions from Stationary Gas Turbines (EPA-453/R-93-007, 01/93) Rule 250, Stationary Gas Turbines (10/17/94) Minor andMajor (nonCTG source) 60 FR 43713 08/23/95 (10/17/94) Rule 250 meets RACT. It meets the ACT.It is consistent with other Regional District rules.

Gasoline Bulk Plants and Terminals Control of Volatile Organic Emissions from Bulk Gasoline Plants (EPA-450/2-77-035, 12/77); Control of Hydrocarbons from TankTruck Gasoline Loading Terminals (EPA450/2-77-026, 12/77); NESHAP Subparts CCCCCC, Gasoline Dispensing Facilities (Area Sources) (1/10/08), R, Gasoline Distribution (Stage 1) (12/14/94), BBBBBB, Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities (Area Sources) (01/10/08) Rule 215, Transfer of Gasoline into Tank Trucks, Trailers, and Railroad Tank Cars at Loading Facilities (06/19/97) Minor 76 FR 5277 01/31/11 (06/19/97) Rule 215 (06/19/97) meets RACT. Rule 215 meets the CTG.Table 1. Existing District Rules That Have Been Determined to Meet RACT

Table 1 - Page 3 of 7 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT),
and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Analysis Used to Determine that the Rule Meets RACT

Gasoline Service Stations (Storage Tanks) Design Criteria for Stage I Vapor Control Systems – Gasoline Service Stations (11/75); Control of Volatile Organic Compound (VOC) Equipment Leaks from Natural Gas/Gasoline Processing Plants (EPA-450/3-83-007, 12/83) ;Technical Guidance – Stage II Vapor Recovery Systems for Control of Vehicle Refueling Emissions at Gasoline Dispensing Facilities (EPA-450/3-91-022a, 11/91); Control of VOC Leaks from Gasoline Tank Trucks and Vapor Collection Systems (EPA-450/2-78-051, 12/78) Rule 213, Gasoline Transfer into Stationary Storage Containers (10/19/93) Minor 62 FR 23365 04/30/97 (10/19/93) Rules 213 (10/19/93) meets RACT. Rule 213 meets all current California requirements for this source category including recent rules for Phase I Enhanced Vapor Recovery system.

Metal Coil, Container, and Closure Control of Volatile Organic Emissions from Existing Stationary Sources – Volume II: Surface Coatings of Cans, Coils, Paper, Fabric, Automobiles, and Light-Duty Trucks (EPA-450/2-77-008, 05/77) Rule 223, Metal Container Coating (10/06/94) Minor 60 FR 2563 01/10/95 (10/06/94) Rule 223 (10/06/94) meets RACT. It meets the CTG. It was SIP approved on 01/10/95. It is consistent with other Regional District rules.

Metal Parts Coatings Control of Volatile Organic Emissions from Existing Stationary Sources (EPA-450/2- 78-015, 06/78); Control Technique Guidelines for Miscellaneous Metal and Plastic Parts Coatings (EPA 453/R-08- 003, 09/08); NESHAP Subpart PPPP, Plastic Parts (4/19/04) Rule 245, Surface Coating of Metal Parts and Products (08/20/09) Minor 76 FR 67366 11/1/11, effective 1/3/12 (08/20/09) Rule 245 (08/20/09) meets RACT. It was amended to meet the CTG.Table 1. Existing District Rules That Have Been Determined to Meet RACT

Table 1 - Page 4 of 7 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT),
and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Analysis Used to Determine that the Rule Meets RACT

Polyester Resin Operations CARB Determination of RACT and Best Available Retrofit Control Technology (BARCT) for Polyester Resin Operations document (01/08/91); Control of VOC Fugitive Emissions from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment (EPA-450/3-83- 006, 03/84); Control of VOC Emissions from Manufacture of High-Density Polyethylene, Polypropylene, and Polystyrene Resins (EPA-450/3-83-008, 11/83); NESHAP Subpart FFFF, Misc. Organic Chemical Production and Processes (MON) (11/10/03) Rule 243, Polyester Resin Operations (04/10/03) Minor 76 FR 61057 10/3/11, effective 12/2/11 (04/10/03) Rule 243 (04/10/03) meets RACT. It meets the CTG. It meets CARB's RACT/BARCT guidance (01/08/91).

Solvent Cleaning Control of Volatile Organic Emissions from Solvent Metal Cleaning (EPA-450/2-77- 022, 77/11); Control Techniques Guidelines for Industrial Cleaning Solvents (EPA-453/R-06-001, 09/06); Alternative Control Techniques Document – Industrial Cleaning Solvents (EPA-453/R-94-015, 1994/02); Halogenated Solvent Cleaners (EPA-450/3-89-030, 89/08); NESHAP Subpart T, Degreasing Organic Cleaners (12/2/94) Rule 216, Organic Solvent Cleaning and Degreasing (12/11/03); see Rule 240 below. Minor Rule 216: 75 FR 24406 05/05/10 (12/11/0) Rule 216 (12/11/03) meets RACT. It was SIP approved after the 2006 CTG (EPA-453/R-06- 001, 09/06). The EPA and CARB provided recommendations for change (EPA's TSD (01/21/10), and e-mail (04/07/10)), but no actions needed to meet RACT.Table 1. Existing District Rules That Have Been Determined to Meet RACT

Table 1 - Page 5 of 7 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT),
and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Analysis Used to Determine that the Rule Meets RACT

Tanks Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed Roof Tanks (EP-450/2-77-036, 12/77); Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks (EPA-450-2/78-047, 12/78); Alternative Control Techniques Document – Volatile Organic Liquid Storage in Floating and Fixed Roof Tanks (EPA-453/R-94-001, 01/94) Rule 212, Storage of Organic Liquids (06/19/97) Minor 74 FR 27714 6/11/09 (06/19/97) Rule 212 (06/19/97) meets RACT. It meets all CTGs and ACTs. It was SIP approved on 06/11/09.

Wood Furniture Coatings Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations (EPA-453/R-96- 007, 04/96) ; NESHAP Subpart JJ, Wood Furniture (12/7/95) Rule 236, Wood Products Coating Operations (10/14/10) Minor 76 FR 71886 11/21/11, effective 1/20/12 (10/14/10) Rule 236 (10/14/10) meets RACT. It was amended to meet the CTG.Table 1. Existing District Rules That Have Been Determined to Meet RACT

Table 1 - Page 6 of 7 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT),
and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Analysis Used to Determine that the Rule Meets RACT

Gasoline Service Stations (Transfer to Vehicle) Design Criteria for Stage I Vapor Control Systems – Gasoline Service Stations (11/75); Control of Volatile Organic Compound Equipment Leaks from NaturalGas/Gasoline Processing Plants (EPA450/3-83-007, 12/83); Technical Guidance – Stage II Vapor Recovery Systems for Control of Vehicle Refueling Emissions at Gasoline Dispensing Facilities (EPA-450/3- 91-022a, 11/91); Control of VOC Leaks from Gasoline Tank Trucks and Vapor Collection Systems (EPA-450/2-78-051, 12/78) Rule 214, Transfer of Gasoline into Vehicle Fuel Tanks (2/21/13) Minor 62 FR 23365 4/30/97 (10/19/93). The 02/21/13 amendment has not been approved. Rule 214 (04/09/09) met RACT. It met the CTG. Rule 214 meets all current California requirements for this source category including recent rules for Phase II Enhanced Vapor Recovery system. It was submitted to EPA (09/15/09) for SIP approval and the District received comments that were addressed in the 2/21/13 amendment. The 2/21/13 amended Rule has not yet been submitted by CARB to EPA.

Graphic Arts Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VIII: Graphic Arts-Rotogravure and Flexography (EPA-450/2-78-033, 12/78); Control Technology Guidelines for Offset Lithographic Printing and Letterpress Printing (EPA-453/R-06-002, 09/06) Rule 239, Graphic Arts Operations (10/11/12) Minor 63 FR 63410 (11/13/98) for old Rule dated 02/13/97, which does
not meet current RACT. The 10/11/12 amendment has not been approved. Rule 239 (10/11/12) was amended to meet RACT. CARB has forwarded it to EPA for SIP approval. EPA has issued a notice of completeness but has not yet approved the amended rule into the SIP. District Rules that are Under Current EPA Review for SIP Approval, or are to be Submitted by ARBTable 1. Existing District Rules That Have Been Determined to Meet RACT

Table 1 - Page 7 of 7 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT),
and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Analysis Used to Determine that the Rule Meets RACT

Solvent Cleaning (see Solvent Cleaning above) Rule 240, Surface Preparation and Cleanup (12/11/03); see Rule 216 above. Minor Rule 240 (the 12/11/03 amendment waiting EPA approval) Rule 240 (12/11/03) meets RACT and is awaiting EPA approval.

Surface Coating of Plastic Parts and Products Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings” [EPA 453/R-08-003], September
2008. Rule 249, Surface Coating of Plastic Parts and Products (08/08/13) Minor District adopted new Rule 249 on 08/08/13 to address the CTG. Awaiting CARB forwarding to EPA.

### Table 2 Negative DeclarationsTable 2. CTG/ACT Source Categories for Which a Negative Declaration is Required

Table 2 - Page 1 of 6 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT), and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Actions Required to Meet RACT

Aerospace Coatings Control of Volatile Organic Compound (VOC) Emissions and MACT from Coating Operations at Aerospace Manufacturing and Rework Operations (EPA-453/R-97-004, 12/97); Aerospace MACT (59 FR-29216, 06/06/94); National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart GG, Aerospace Manufacturing and Rework Facilities (03/27/98) No Major or Minor exceeding CTG thresholds or that require District Permit Negative declaration to be adopted since the CTG applicability threshold is 25 tons/year for sources in moderate, serious, or sever non-attainment areas, and the potential VOC emissions from existing sources in the District are less than 25 tons/year.

Automobile and Light-duty Truck Assembly Coatings Control Techniques Guidelines for Automobile and Light-Duty Truck Assembly Coatings (EPA 453/R-08-006, 09/08); Protocol for Determining the Daily Volatile Organic Compound Emission Rate of Automobile and Light-Duty Truck Primer-Surfacer and Topcoat Operations (EPA 453/R-08-002, 09/08). Also, Control of Volatile Organic Emissions from Existing Stationary Sources – Volume II: Surface Coatings of Cans, Coils, Paper, Fabric, Automobiles, and Light-Duty Trucks (EPA-450/2-77-008, 05/77) None Negative declaration to be adopted. There are no sources for this category in the District. Source Categories with CTGsTable 2. CTG/ACT Source Categories for Which a Negative Declaration is Required

Table 2 - Page 2 of 6 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT), and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Actions Required to Meet RACT

Dry Cleaning (Petroleum) Control of VOC Emissions from Large Petroleum Dry Cleaners (EPA-450/3-82-009, 09/82). New Source Performance Standards for Petroleum Dry Cleaners (40 CFR 60 Subpart JJJ, 10/00) Rule 227, Petroleum Dry Cleaning Operations (02/05/91); rescinded 04/12/12 No Major or Minor exceeding CTG thresholds or that require District Permit Negative declaration to be adopted. There are no sources for this category in the District. The previoulsy existing Rule was rescinded. Rule 227 was not SIP approved and the District has no large petroleum dry cleaners that would be covered by the CTG for Large Petroleum Dry Cleaners, therefore the District does not need a RACT rule for this category. The NSPS for Petroleum Dry Cleaners, 40 CFR 60 Subpart JJJ exempts dry cleaners which have a capacity of less than 84 pounds per load. This 84 pound size will be considered the definition of “large” relative to the CTG.

Fiberglass Boat Manufacturing Control Technique Guidelines for Fiberglass Boat Manufacturing Materials (EPA 453/R-08- 004, 09/08) None Negative declaration to be adopted. There are no sources for this category in the District. Flexible Package Printing Control Technique Guidelines for Flexible Package Printing (EPA-453/R-06-003, 09/06) None Negative declaration to be adopted. There are no sources for this category in the District. Large Appliances Surface Coatings Control Technique Guidelines for Large Appliance Coatings (EPA 450/2-77-034, 12/77); Control Technique Guidelines for Large Appliance Coatings (EPA 453/R-07- 004, 09/07); NESHAP Subpart NNNN, Large Appliances (7/23/02) None Negative declaration to be adopted. There are no sources for this category in the District.Table 2. CTG/ACT Source Categories for Which a Negative Declaration is Required

Table 2 - Page 3 of 6 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT), and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Actions Required to Meet RACT

Magnet Wire Control of Volatile Organic Emissions from Existing Stationary Sources, Volume IV: Surface Coating of Insulation of Magnet Wire (EPA-450/2-77-033, 12/77); Control of Volatile Organic Emissions from Existing Stationary Sources, Volume IV: Surface Coating of Insulation of Magnet Wire (EPA-450/2-77-033, 12/77) None Negative declaration to be adopted. There are no sources for this category in the District.

Metal Furniture Coatings Control of Volatile Organic Emissions from Existing Stationary Sources (EPA-450/2-77- 032, 12/77); Control Techniques Guidelines for Metal Furniture Coatings (EPA-453/R-07- 005, 09/07); NESHAP Subpart RRRR, Metal Furniture (5/23/03) None Negative declaration to be adopted. There are no sources for this category in the District.

Natural Gas / Gasoline Processing Control of VOC Equipment Leaks from Natural Gas / Gasoline Processing Plants (EPA-450/2- 83-007, 12/83) None Negative declaration to be adopted. There are no sources for this category in the District.

Paper and Fabric Control of Volatile Organic Emissions from Existing Stationary Sources – Volume II: Surface Coatings of Cans, Coils, Paper, Fabric, Automobiles, and Light-Duty Trucks (EPA-450/2-77-008, 05/77) None Negative declaration to be adopted. There are no sources for this category in the District.

Paper, Film, and Foil Coatings Control Techniques Guidelines for Paper, Film, and Foil Coatings (EPA-453/R-07-003, 09/07) 230, Plastic Products and Materials – Paper Treating Operations (06/28/94); rescinded 4/12/12 None 59 FR 64336 (12/14/1994), for Rule 06/28/94. Rule 230 was rescinded 4/12/12. The only source, Formica, is shutdown (06/29/07).Table 2. CTG/ACT Source Categories for Which a Negative Declaration is Required

Table 2 - Page 4 of 6 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT), and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Actions Required to Meet RACT

Pharmaceutical Products Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products (EPA-450/2-78-029, 12/78) None Negative declaration to be adopted. There are no sources for this category in the District.

Refineries Control of Refinery Vacuum Producing Systems, Wastewater Separators, and Process Unit Turnarounds (EPA-450/2-77- 025, 10/77); Control of VOC Leaks from Petroleum Refinery Equipment (EPA-450/2-78- 036, 06/78) None Negative declaration to be adopted. There are no sources for this category in the District.

Rubber Tire Control of Volatile Organic Emissions fromManufacture of Pneumatic Rubber Tires (EPA450/2-78-030, 12/78) None Negative declaration to be adopted. There are no sources for this category in the District. Ships/Marine Coating Control Technique Guidelines for Shipbuilding and Ship Repair Operations (Surface Coating) (61 FR 44050, 08/27/96) ); Alternative Control Technology Document – Surface Coating Operations at Shipbuilding and Ship Repair Facilities (EPA-453/R-94-032, 04/94); NESHAP Subpart II, Shipbuilding and Ship Repair (surface coating) (12/16/96) None Negative declaration to be adopted. There are no sources for this category in the District.

Synthetic Organic Chemicals Control of VOC Emissions from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry (EPA-450/3-84-015, 12/84); Control of VOC Emissions from Reactor Processes and Distillation Operations in SOCMI (EPA-450/4-91-031, 08/93) None Negative declaration to be adopted. There are no sources for this category in the District.Table 2. CTG/ACT Source Categories for Which a Negative Declaration is Required

Table 2 - Page 5 of 6 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT), and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Actions Required to Meet RACT

Bakery Ovens Alternative Control Technology Document – Bakery Ovens (EPA-453/R-92-017, 12/92) None ACT or Other RACT Guidance. There are no sources for this category in the District.
Cement Kilns NOx Emissions from Cement Manufacturing (EPA-453/R-94-004, 03/94) None ACT or Other RACT Guidance. There are no sources for this category in the District.
Chemical Plants Control Techniques for Fugitive VOC Emissions from Chemical Process Facilities (EPA-625/R-93-005, 03/94) None ACT or Other RACT Guidance. There are no sources for this category in the District. Ethylene Oxide Alternative Control Technology Document – Ethylene Oxide Sterilization / Fumigation Operations (EPA-450/3-89-007, 03/89) None ACT or Other RACT Guidance. There are no sources for this category in the District.
Glass Furnaces NOx Emissions from Glass Manufacturing (EPA-453-R-94-037, 01/93) None ACT or Other RACT Guidance. There are no sources for this category in the District.
Ink and Paint Manufacture Control of VOC Emissions from Ink and Paint Manufacturing Processes (EPA-450/3-92-013, 04/92) None ACT or Other RACT Guidance. There are no sources for this category in the District.
Iron and Steel NOx Emissions from Iron and Steel Mills (EPA453/R-94-065, 09/94) None ACT or Other RACT Guidance. There are no sources for this category in the District.
Leather and Tanning Air Emissions and Control Technology for Leather Tanning and Finishing Operations (EPA-453/R-93-025, 06/93) None ACT or Other RACT Guidance. There are no sources for this category in the District. Nitric and Adipic Acid NOx Emissions from Nitric and Adipic Acid Manufacturing (EPA-453/3-91-026, 12/91) None ACT or Other RACT Guidance. There are no sources for this category in the District. Organic Waste Process Vents Alternative Control Technology Document - Organic Waste Process Vents (EPA-450/3-91- 007, 1990/12) None ACT or Other RACT Guidance. There are no sources for this category in the District.
Pesticides Control of VOC Emissions from theApplication of Agricultural Pesticides (EPA453/R-92-011, 03/93) None ACT or Other RACT Guidance. There are no sources for this category in the District. Source Categories with ACT and Other RACT Guidance (not CTGs)Table 2. CTG/ACT Source Categories for Which a Negative Declaration is Required

Table 2 - Page 6 of 6 Source Category RACT Guidance Document -- Control Technique Guidelines (CTG), Alternative Control Technology (ACT), and Others PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Actions Required to Meet RACT

Plywood Veneer Dryers Control Techniques for Organic Emissions from Plywood Veneer Dryers (EPA-450/3-83-
012 None ACT or Other RACT Guidance. There are no sources for this category in the District. Polymeric Foam Product Manufacturing Control of VOC Emissions from Polystyrene Foam Manufacturing (EPA-450/3-90-020, 09/90) None ACT or Other RACT Guidance. There are no sources for this category in the District.
Wastewater Control of VOC Emissions from Industrial Wastewater (EPA-453/D-93-056, 09/92) None ACT or Other RACT Guidance. There are no sources for this category in the District.

### Table 3 Every Feasible MeasureTable 3. Every Feasible Measure (EFM)

Table 3 - Page 1 of 4 Source Category CARB -- Every Feasible Control Measure (EFM) PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Actions Required to Meet EFM

Adhesives SMAQMD Rule 460 (11/30/00); SJUAPCD Rule 4653 (09/16/10); BAAQMD Reg. 8, Rule 51 (12/02/09); SCAQMD Rule 1168 (01/07/05); SDCAPCD Rule 67.21 (05/14/08); YSAQMD Rule R2-33 (05/14/08); CARB- Reasonably Available Control Technology (RACT) (1998) Rule 235, Adhesives (10/11/12) Minor Approved 78 FR 53711 8/30/13, effective 10/29/13 Rule 235 emission reduction measures will be equal to equivalent measures in the regional districts rules.

Aerospace Coatings SCAQMD Rule 1124 (12/13/96); SDCAPCD Rule 67.9 0 (04/30/97) No Major or Minor There are no sources subject to this source category in the District.

Architectural Coatings CARB Suggested Control Measure (SCM) (2007); SCAQMD Rule 1113 (07/13/07) Rule 218, Architectural Coatings (10/14/10) Minor 76 FR 75795 12/5/11, effective 2/3/12 (10/11/12) Rule 218 considers the State emission reduction measures equal to the 2007 CARB SCM.

Automotive Refinishing CARB Suggested Control Measure (SCM) (10/05); SCAQMD Rule 1151 (12/02/05) Rule 234, Automotive Refinishing (10/14/10) Minor Rule 234 considers the State emission reduction measures equal to the 2005 CARB SCM.

Bakery Ovens SMAQMD Rule 458 (09/05/96); SJUAPCD Rule 4693 (05/16/02); BAAQMD Reg. 8, Rule 42 (06/01/94); SCAQMD Rule 1153 (01/13/95); SDCAPCD Rule 67.24 (05/15/96) None There are no sources subject to this source category in the District.

Fugitive Emissions from Chemical Plants BAAQMD Reg. 8, Rules 22 (06/01/94), 28 (06/15/94), 18 (01/07/98) None There are no sources subject to this source category in the District.

Fugitive Emissions from Oil and Gas Production RACT Determination of Fugitive Emissions of Fugitive Emissions of VOCs from Oil and Gas Production and Processing; Facilities, Refineries, Chemical Plants, and Pipeline Transfer Stations (12/08/93) None There are no sources subject to this source category in the District.Table 3. Every Feasible Measure (EFM)

Table 3 - Page 2 of 4 Source Category CARB -- Every Feasible Control Measure (EFM) PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Actions Required to Meet EFM

Fugitive Emissions from Petroleum Refineries BAAQMD Reg. 8, Rules 28 (06/15/94), 18 (01/07/98) None There are no sources subject to this source category in the District.

Gasoline Terminals and Bulk Plants SMAQMD Rules 446 (11/16/93), 447 (04/02/98); SJUAPCD Rules 4621 (12/20/07), 4623 (05/19/05); BAAQMD Reg. 8, Rules 33 (4/15/09), 39 (04/15/09), 5 (10/12/06); SCAQMD Rules 462 (05/14/99), 463 (05/06/08); SDCAPCD Rules 61.1 ( 07/26/00), 61.2 (07/26/00), 61.3 (10/16/03), 61.3.1 (03/01/06), 61.8 (01/13/87).1, 61.4.1 (03/26/08); YSAQMD Rules R2-13 (05/25/94), R2-21 (09/14/05) Rule 215, Transfer of Gasoline into Tank Trucks, Trailers, and Railroad Tank Cars at Loading Facilities (06/19/97) Minor 76 FR 5277 01/31/11 (06/19/97) Rule 215 emission reduction measures are equal to equivalent measures in the regional districts rules.

Graphic Arts, Lithographic and Letterpress Printing SMAQMD Rule 450 (10/23/08); SJUAPCD Rule 4607 (12/08/08); BAAQMD Reg. 8, Rule 20 (11/19/08); SCAQMD Rules 1130 (10/8/99); SDCAPCD Rule 67.16 (05/15/96) 239, Graphic Arts Operations (10/11/12) Minor 63 FR 63410 11/13/98 (02/13/97) Rule 239 emission reduction measures will be revised to meet equivalent measures in the regional districts rules. Awaiting EPA action on 10/11/12 amendment.

Industrial Boilers

≥ 5 million Btu/hr SMAQMD Rule 411 (03/25/10); SJUAPCD Rules 4305 (08/21/03), 4306 (10/16/08); BAAQMD Reg. 9, Rule 7 (07/30/08); SDCAPCD Rules 69 (12/12/95),69.2 (09/27/94); YSAQMD Rule R2-27 (08/14/96); CARB - RACT and Best Available Retrofit Control Technology (BARCT) for Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters (07/18/91) 231, Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters (10/09/97) Minor 76 FR 67366 11/1/11, effective 1/3/12 (10/09/97) Rule 231 emission reduction measures are equal to equivalent measures in the regional districts rules.

246, Natural Gas Fired Water Heaters (06/19/97) Minor 76 FR 67366 11/1/11, effective 1/3/12 (06/19/97) Rule 246 applies to natural gas water heater < 750,000 Btu/hr and is consistent with the regional districts rules. Large Water Heaters and Small Boilers < 2 million Btu/hr SCAQMD Rule 1146.1 (5/13/94) and 1146.2 (05/05/06); SMAQMD Rule 411 (8/23/07) and 414 (8/1/96); SJUAPCD Rule 4307 (5/19/11) and 4308 (12/17/09); BAAQMD Reg. 9, Rule 6 (11/7/07) d R l 7 (9/16/92) YSAQMD R lTable 3. Every Feasible Measure (EFM)

Table 3 - Page 3 of 4 Source Category CARB -- Every Feasible Control Measure (EFM) PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Actions Required to Meet EFM

Rule 247, Natural Gas-Fired Water Heaters, Small Boilers, and Process Heaters (10/10/13) Minor Rule 247 for all new boilers and water heaters within the heat input range of 75,000 to 5 million Btu/hr -- a SIP commitment by 2015 -- Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan. Rule 247 10/10/13 withdrawn pending scheduled amendment of Rule 247 on 02/13/14.

Marine Coatings SCAQMD Rule 1106 (01/13/95); NESHAP 60 FR 64330 (12/15/95) None There are no sources subject to this source category in the District.

Metal Parts andProducts (NonArchitectural) SMAQMD Rule 451 (09/25/2008); SJUAPCD Rule 4603 (09/17/09); BAAQMD Reg. 8, Rule 19 (10/16/02); SCAQMD Rule 1107 (01/06/06); SDCAPCD Rule 67.3 (04/9/03); YSAQMD Rule R2-25 (05/14/08) 245, Surface Coating of Metal Parts and Products (08/20/09) Minor Rule 245 is consistent with the regional districts rules. It was recently amended to meet the Control Technique Guidelines (CTG).

Pleasure Craft Coating Operations SCAQMD Rule 1106.1 (02/12/99) None There are no sources subject to this source category in the District.

Polyester Resin Operations SMAQMD Rule 465 (09/25/08); SJUAPCD Rule 4684 (09/17/09); BAAQMD Reg. 8, Rule 50 (12/2/09); SCAQMD Rule 1162 (07/08/05); SDCAPCD Rule 67.12 (05/15/96); YSAQMD Rule R2-30 (05/14/08) 243, Polyester Resin Operations (04/10/03) Minor Rule 243 considers the State emission reduction measures equal to the 2007 CARB's RACT/BARCT.

Polymeric Foam Product Manufacturing SJUAPCD Rule 4682 (09/20/07); SDCAPCD (05/15/96); SCAQMD Rule 1175 (09/07/07) None There are no sources subject to this source category in the District.

Portland Cement Kilns SCAQMD Rule1112 (06/06/86) None There are no sources subject to this source category in the District. Refinery Boilers SCAQMD 1109 (08/05/88) BAAQMD Reg. 9 Rule10 (01/05/94) None There are no sources subject to this source category in the District. (11/7/07) and Rule 7 (9/16/92); YSAQMD Rule 2.37 (4/8/09)Table 3. Every Feasible Measure (EFM)

Table 3 - Page 4 of 4 Source Category CARB -- Every Feasible Control Measure (EFM) PCAPCD Rule (Date Last Amended) PCAPCD Sources Most Recent SIP Approval Actions Required to Meet EFM

Restaurants, Chain Driven Charbroilers SJUAPCD Rule 4692 (9/17/09); SCAQMD Rule1138 (11/14/97) Minor There are no sources subject to this source category in the District.

Semiconductor Manufacturing BAAQMD Reg. 8, Rule 30 (6/15/94); SCAQMD Rule 1164 (1/13/95); VCAPCD Rule 74.21(4/6/93) Rule 244, Semiconductor Operations (02/09/95) Minor 61 FR 38571 07/25/96 (02/09/95) Rule 244 meets RACT. There is no available federal CTG guidance for this source category. The Rule was SIP approved on 07/25/96.
Small Industrial Boilers (1 million Btu/hr to 5 million Btu/hr) SMAQMD Rule 414 (08/23/07); SJUAPCD Rules 4307(10/16/08); 4308 (12/17/09) Rule 247, Natural Gas-Fired Water Heaters, Small Boilers, and Process Heaters (10/10/13) Minor Rule 247 for all new boilers and water heaters within the heat input range of 75,000 to 5 million Btu/hr -- a SIP commitment by 2015 -- Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan. Rule 247 (10/10/13) withdrawn pending scheduled amendment of Rule 247 on 02/13/14.

Solvent Cleaning SMAQMD Rule 466 (09/25/08); SJUAPCD Rules 4663 (09/20/07), 4461 (09/20/07); BAAQMD Reg.8, Rule 16 (10/16/02); SCAQMD Rules 1122 (05/1/09), 1171 (05/1/09); SDCAPCD Rule 67.6.1 (05/23/07) 216, Organic Solvent Cleaning and Degreasing (12/11/03); 240, Surface Preparation and Cleanup (12/11/03) Minor 75 FR 24406 05/05/10 (12/11/03) Rule 216 emission reduction measures will be equal to equivalent measures in the regional districts rules.

Surface Coating of Plastic Parts and Products BAAQMD Reg. 8, Rule 31 (10/16/02); SCAQMD Rule 1145 (12/04/09) Rule 249, Surface Coating of Plastic Parts and Products (08/08/13) Minor District adopted new Rule 249 to address this source category. Awaiting forwarding by ARB to EPA.